Washington, D.C. July 30, 2019 – The American College of Physicians (ACP) strongly supports proposed changes in Medicare payments to physicians that would recognize the value of cognitive services in providing quality patient care. These provisions were included in the proposed Medicare Physician Fee Schedule (PFS) for 2020 that was released by the Centers for Medicare and Medicaid Services (CMS) on July 29.

“Internists are excited to see that CMS is proposing significant improvements in the physician fee schedule that would support physicians in providing the highest quality care to patients,” said Robert McLean, MD, FACP, president, ACP. “This includes recognizing the value of primary care services, and efforts to streamline and reduce documentation burdens, in line with ACP’s Patients Before Paperwork initiative.”

ACP is pleased that CMS has proposed many positive improvements to the PFS, particularly the improved valuation and documentation changes for E/M services. These improvements include:

Increased payments for E/M services: ACP is very encouraged CMS adopted recommendations from the Specialty Society Relative Value Scale Update Committee (RUC) to increase payments for office/outpatient E/M visits starting in 2021. ACP was a leader, along with several other health care societies, in this push to improve payments for these historically undervalued services.

Retaining separate payment levels for each of the E/M codes: The E/M coding changes will retain five levels of coding for established patients, reduce the number of levels to four for office/outpatient E/M visits for new patients, and revise the code definitions.

Improved documentation for E/M services: The changes would also allow physicians to choose the E/M visit level based on either medical decision-making or time spent—something that ACP has long been seeking. They also revise the times and medical decision making process for all of the codes, requiring performance of history and exam only as medically appropriate.

Improved accuracy in tracking time spent: When time is tracked to determine the level of service, total time spent on all activities for that patient on the day of service are counted. This is an end to the “greater than 50 percent of time spent on counseling and coordination of care” requirement. All the work for an E/M visit would be considered equally valid and important, whether it be reviewing the notes before a physician enters the room, or developing a differential diagnosis after the appointment ends.

Additional add-on codes: We are happy CMS proposes moving forward with plans for add on coding. CMS recognizes that the revised E/M code set does not account for additional resource costs in furnishing primary care and certain specialty visits. The agency is seeking comment if more than one code would be beneficial for this purpose. CMS would also introduce a 15 minute, prolonged service code to take effect in 2021—a code that ACP has long been seeking as well.

CMS made several other proposed changes that ACP supports, including:

Recognizing that it is burdensome to obtain consent for every brief electronic check in or non-face-to-face service. Therefore, the Agency seeks input to simplifying consents for non-face-to-face services to help reduce administrative burdens

Improving payments for chronic care management codes by paying for each 20 minute increment of time spent, instead of for a single 20 minute block of time.

Introducing principal care management services to reimburse for patients who need chronic care management, but only have one high-risk chronic condition.

Increasing the value of transitional care management codes to increase their use, since good transitional care management is associated with reduced readmission rates, lower mortality, and lower healthcare costs.

Additionally, ACP appreciates changes proposed to the 2020 Quality Payment Program to reduce clinician burden. These include ongoing efforts to remove low value measures; provisions related to vendor accountability; and the new Merit-based Incentive Payment System’s (MIPS) Value Pathway, which has the potential to further streamline currently siloed MIPS performance categories--something ACP has called for in the past. ACP will continue to analyze the changes more closely.

Also released from CMS yesterday, the proposed 2020 Hospital Outpatient Prospective Payment System rule seeks to improve transparency by requiring hospitals to make public their gross charges, as well as payer-specific negotiated charges. The rule also continues phasing in site-neutrality provisions to bring payment for off-campus hospital outpatient department visits in line with physician office visits and expand the list of services that can be provided in an outpatient setting. ACP supports policies that improve price transparency and the affordability of medical care for patients; however, emphasizes the importance of ensuring this information is up-to-date and in appropriate context, including expected out of pocket costs and accompanying quality data.

“By making changes to shore up payment for primary care services, CMS is ensuring that they are putting patients first and helping them access the care they need,” said Dr. McLean. “We applaud CMS for proposing these historic changes and look forward to working with regulatory leaders towards a plan that continues to address administrative and documentation burdens while ensuring quality patient care.”

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About the American College of Physicians

The American College of Physicians is the largest medical specialty organization in the United States with members in more than 145 countries worldwide. ACP membership includes 159,000 internal medicine physicians (internists), related subspecialists, and medical students. Internal medicine physicians are specialists who apply scientific knowledge and clinical expertise to the diagnosis, treatment, and compassionate care of adults across the spectrum from health to complex illness. Follow ACP on Twitter, Facebook, and Instagram.